Petition for Exemption

Adam Stephens

A. Stephens Photography & Video

4935 Baker Plantation

Acworth, GA 30101

I, Adam Stephens, hereby submit this petition for exemption under Section 333; FAA 

Modernization and Reform Act of 2012, Public Law 112-95 FEB. 14, 2012, Section 333.

I request this exemption in order to operate my UAV/UAS, DJI Phantom 3 Professional 

Quad copter Aircraft, in order to provide services for profit to include aerial photography, 

aerial cinematography, aerial filming and photography for real estate, construction firms, 

aerial mapping, special events to include but not limited to weddings, private or public 

parties/events, business advertising, promotional events, geological surveying, and 

environmental studies.

The ability to provide these services to other local businesses and individuals in my 

community will benefit them by opening up opportunities they otherwise did not have 

before. Traditional methods of aerial photography/videography are simply not viable 

options for the average consumer as they are costly and involve greater risks to everyone 

involved; i.e. the use of larger aircraft carrying humans and flammable fuel. By utilizing 

the UAV/UAS the same results can be achieved with much safer conditions.

Prior to each flight/operation of the UAV/UAS, I will conduct a Pre-Flight Safety 

Inspection. 

Only the manufacturers authorized repair facilities/ providers will perform any and all 

repairs. Flights will not take place over densely populated areas or private property 

without the owners permission. The UAV/UAS will only be operated within visual line of 

sight and will not be flown near airports or above 400 feet. The FAA can be confident that 

operations of this UAV/UAS will achieve at least the equivalent or greater level of safety.

The specific sections of 14 C.F.R from which I am seeking exemption are as follows:

14 C.F.R. Part 21;

14 C.F.R. 45.23(b);

14 C.F.R. 61.101(e)(4), & (5);

14 C.F.R. 61.113(a) & (b);

14 C.F.R. 61.133 (a);

14 C.F.R. 61.23(a) & (c);

14 C.F.R 91.7(a)

14 C.F.R. 91.9(b)(2);

14C.F.R. 91.109(a);

14 C.F.R. 91.119;

14 C.F.R. 91.121;

14 C.F.R. 91.151(a);

14 C.F.R. 91.203(a) & (b);

14 C.F.R. 91.405(a);

14 C.F.R. 91.407(a)(1);
14 C.F.R. 91.409(a)(2};

14 C.F.R. 91.417(a) & (b).

In summary, given the small size of the UAS’s involved and the restricted controlled 

environment within which they will operate, the applicant fits within that zone of safety (an 

equivalent level of safety) in which Congress envisioned that the FAA must, by 

exemption, allow commercial operations of UASs to commence immediately. These 

limitations and conditions to which Adam Stephens agrees to be bound when conducting 

commercial operations under an FAA issued exemption including:

1. The UAS will weigh less than 55 lbs. 

2. Flights will be operated within line of sight of operator. 

3. Maximum total flight time for each operational flight will be 30 minutes. 4. Flights will 

be terminated at 15% battery power reserve. 

5. Flights will be operated at an altitude of no more than 400 feet AGL 

6. The UAS will only operate within a controlled area as defined in the Procedures. 

7. The operator will post advisor notice around the controlled area. 

8. The operator will have been trained in operation of UAS generally and received up-todate information on the particular UAS to be operated as required.

9. If the UAS loses communications or loses its GPS signal, the UAS will have capability 

to return to a pre-determined location within the Security Perimeter and land. 

10. The UAS will have the capability to abort a flight in case of unpredicted obstacles or 

emergencies.

11. UAS operator will be trained and certified in the proper safety and operations of the 

UAS. 

Please find the at the following url

User Manual - http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_User_Manual_v1.4

_en_0915.pdf

Quick Start Guide - http://download.djiinnovations.com/downloads/phantom_3/en/Phantom_3_Professional_Quick_Start_Guide

_en_v1.2.pdf

Smart Flight Battery Safety Guidelines - http://download.djiinnovations.com/downloads/phantom_3/en/Intelligent_Flight_Battery_Safety_Guidelines_

en.pdf

I truly thank you for your consideration.

Sincerely,

Adam Stephens

A. Stephens Photography